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	<title>Comments on: Agile development in a FDA regulated setting</title>
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	<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/</link>
	<description>Software Development and Biomedical Engineering</description>
	<pubDate>Mon, 06 Oct 2008 20:06:35 +0000</pubDate>
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		<title>By: Missing Fundamental &#187; Blog Archive &#187; SDLC, Design Methods #1: A waterfall of similitudes</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-914</link>
		<dc:creator>Missing Fundamental &#187; Blog Archive &#187; SDLC, Design Methods #1: A waterfall of similitudes</dc:creator>
		<pubDate>Tue, 16 Sep 2008 06:07:42 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-914</guid>
		<description>[...] readings: Agile v. FDA  Bob on Medical Device Software    Posted by marm on September 16, 2008   Design, [...]</description>
		<content:encoded><![CDATA[<p>[...] readings: Agile v. FDA  Bob on Medical Device Software    Posted by marm on September 16, 2008   Design, [...]</p>
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		<title>By: Ilja Preuss</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-501</link>
		<dc:creator>Ilja Preuss</dc:creator>
		<pubDate>Tue, 11 Mar 2008 07:11:57 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-501</guid>
		<description>"The purpose of the iterative development is to facilitate requirements changes between each iteration."

That is one of the purposes, yes. Another is to get earlier feedback on whether what we are building actually works the way it is supposed to work, and to build that learning into future iterations. Another is to more reliably measure progress, in terms of Running Tested Features.

"I just don’t see how a cost-effective quality system process implementation can be accomplished."

Anecdotal Evidence seems to suggest that an Agile approach actually is more cost effective than a waterfall approach. I think the most important reason is that the earlier we get feedback - for example from a failing test - the less costly it is to incorporate that feedback into the product.

"If you are (or have ever been) part of an Agile development team for a FDA regulated product I’d love to here about your experiences and how you were able to resolve the types of issues presented here."

I suggest you do some research on PatientKeeper.</description>
		<content:encoded><![CDATA[<p>&#8220;The purpose of the iterative development is to facilitate requirements changes between each iteration.&#8221;</p>
<p>That is one of the purposes, yes. Another is to get earlier feedback on whether what we are building actually works the way it is supposed to work, and to build that learning into future iterations. Another is to more reliably measure progress, in terms of Running Tested Features.</p>
<p>&#8220;I just don’t see how a cost-effective quality system process implementation can be accomplished.&#8221;</p>
<p>Anecdotal Evidence seems to suggest that an Agile approach actually is more cost effective than a waterfall approach. I think the most important reason is that the earlier we get feedback - for example from a failing test - the less costly it is to incorporate that feedback into the product.</p>
<p>&#8220;If you are (or have ever been) part of an Agile development team for a FDA regulated product I’d love to here about your experiences and how you were able to resolve the types of issues presented here.&#8221;</p>
<p>I suggest you do some research on PatientKeeper.</p>
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		<title>By: Chip Weller</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-232</link>
		<dc:creator>Chip Weller</dc:creator>
		<pubDate>Tue, 23 Oct 2007 15:43:11 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-232</guid>
		<description>The FDA documentation is written as if a waterfall process is used. It does claim in various documents that a waterfall process is not required. For example http://www.fda.gov/cdrh/comp/guidance/938.html#_Toc517237956.

We typically use a waterfall approach for requirements (although there are changes expected, often TBDs remaining, at the approval) and for the software architecture. Then we use an iterative approach on the detailed design, coding, and verification steps. Validation is done at the end. This approach is certainly not agile. Our concern in using Agile is justifying to the FDA the lack of the design input stage gate. While I think this could be done, our typical clients are somewhat regulatory risk adverse.</description>
		<content:encoded><![CDATA[<p>The FDA documentation is written as if a waterfall process is used. It does claim in various documents that a waterfall process is not required. For example <a href="http://www.fda.gov/cdrh/comp/guidance/938.html#_Toc517237956" rel="nofollow">http://www.fda.gov/cdrh/comp/guidance/938.html#_Toc517237956</a>.</p>
<p>We typically use a waterfall approach for requirements (although there are changes expected, often TBDs remaining, at the approval) and for the software architecture. Then we use an iterative approach on the detailed design, coding, and verification steps. Validation is done at the end. This approach is certainly not agile. Our concern in using Agile is justifying to the FDA the lack of the design input stage gate. While I think this could be done, our typical clients are somewhat regulatory risk adverse.</p>
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		<title>By: Bob on Medical Device Software &#187; Blog Archive &#187; Medical Device Software Development—Going Agile</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-196</link>
		<dc:creator>Bob on Medical Device Software &#187; Blog Archive &#187; Medical Device Software Development—Going Agile</dc:creator>
		<pubDate>Mon, 15 Oct 2007 03:54:38 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-196</guid>
		<description>[...] not so sure about that. As I&#8217;ve pointed out before, because of the validation requirements those guidelines are much better suited for the Waterfall [...]</description>
		<content:encoded><![CDATA[<p>[...] not so sure about that. As I&#8217;ve pointed out before, because of the validation requirements those guidelines are much better suited for the Waterfall [...]</p>
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		<title>By: CK</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-158</link>
		<dc:creator>CK</dc:creator>
		<pubDate>Sat, 29 Sep 2007 18:27:28 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-158</guid>
		<description>Very informative and thanks for the post. I was hoping you could help me figure out how a small company can do FDA approved sfw development without setting up all the processes in place. I was hoping that there are companies one could outsource the sfw work to. Companies that understand the FDA process and can design, implement, deliver and maintain the software for a device maker. Is there any one out there like this?</description>
		<content:encoded><![CDATA[<p>Very informative and thanks for the post. I was hoping you could help me figure out how a small company can do FDA approved sfw development without setting up all the processes in place. I was hoping that there are companies one could outsource the sfw work to. Companies that understand the FDA process and can design, implement, deliver and maintain the software for a device maker. Is there any one out there like this?</p>
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		<title>By: Designer Dude</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-117</link>
		<dc:creator>Designer Dude</dc:creator>
		<pubDate>Thu, 20 Sep 2007 08:53:04 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-117</guid>
		<description>Hi! Nice blog posting about Agile development in a FDA regulated setting. I would have to agree with you on this one. I am going to look more into website design software. This Thursday I have time.</description>
		<content:encoded><![CDATA[<p>Hi! Nice blog posting about Agile development in a FDA regulated setting. I would have to agree with you on this one. I am going to look more into website design software. This Thursday I have time.</p>
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		<title>By: Agile and fixed price contracts &#187; SDLC Blog</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-116</link>
		<dc:creator>Agile and fixed price contracts &#187; SDLC Blog</dc:creator>
		<pubDate>Wed, 19 Sep 2007 22:35:40 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-116</guid>
		<description>[...] Agile development in a FDA regulated setting: this post explains why agile methodologies have a long way to go before we see them commonly used in regulated environments, in this case, FDA. [...]</description>
		<content:encoded><![CDATA[<p>[...] Agile development in a FDA regulated setting: this post explains why agile methodologies have a long way to go before we see them commonly used in regulated environments, in this case, FDA. [...]</p>
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		<title>By: Look here for the hard answers &#171; Tuff Stuff</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-77</link>
		<dc:creator>Look here for the hard answers &#171; Tuff Stuff</dc:creator>
		<pubDate>Tue, 04 Sep 2007 13:48:54 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-77</guid>
		<description>[...] On a related note, check out Agile development in a FDA regulated setting. [...]</description>
		<content:encoded><![CDATA[<p>[...] On a related note, check out Agile development in a FDA regulated setting. [...]</p>
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		<title>By: Look here for the hard answers - Jeremy D. Miller -- The Shade Tree Developer</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-76</link>
		<dc:creator>Look here for the hard answers - Jeremy D. Miller -- The Shade Tree Developer</dc:creator>
		<pubDate>Tue, 04 Sep 2007 09:48:55 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-76</guid>
		<description>[...] a related note, check out Agile development in a FDA regulated setting.   Published Sep 04 2007, 05:49 AM by Jeremy D. [...]</description>
		<content:encoded><![CDATA[<p>[...] a related note, check out Agile development in a FDA regulated setting.   Published Sep 04 2007, 05:49 AM by Jeremy D. [...]</p>
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		<title>By: Bob on Medical Device Software &#187; Blog Archive &#187; Software Defects and the FDA</title>
		<link>http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-69</link>
		<dc:creator>Bob on Medical Device Software &#187; Blog Archive &#187; Software Defects and the FDA</dc:creator>
		<pubDate>Sun, 26 Aug 2007 01:56:40 +0000</pubDate>
		<guid isPermaLink="false">http://rdn-consulting.com/blog/2007/07/22/agile-development-in-a-fda-regulated-setting/#comment-69</guid>
		<description>[...] failure&#8217;, but may be close). I think the FDA &#8220;rule book&#8221; (as I briefly describe here) is a full product life cycle quality system that generally meets its intended purpose. It [...]</description>
		<content:encoded><![CDATA[<p>[...] failure&#8217;, but may be close). I think the FDA &#8220;rule book&#8221; (as I briefly describe here) is a full product life cycle quality system that generally meets its intended purpose. It [...]</p>
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